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Hyatt & Rhoads, lp.c.
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ATTORNEYS AND COUNSELORS constancecpattersoniga.
WAYNE S HYATT (GA, DC & NY) CONSTANCE C HAI I LHbUN (GA)
JAMES B RHOADS (GA, DC & PA) DAVID A. HERRIGEL (GA)
JO ANNE P STUBBLEFIELD(GA) 225 PEACHTREE STREET, N.E. SUSANLOALY(CA)
DEAN A RIDDLE (GA, NC & TX) -,,—w , -, ,-> ^ M MAXINE HICKS (GA)
DAVID N. DOROUGH (GA) SUITE 1200 LANCE E WILLIAMS (TX)
JONATHAN F YOUNG (GA) ATI ANITA GFORriA^mO^ ROBE RT M BLEND (TX)
AMYGR.FFITHDEVER(GA) ATLANTA, GEORGIA 30303 f ANTHONY WOXLEY.H(GA)
404/659-6600 or counsel
" NOT ADMITTED AND NOT _ DUNBAR a MASSlE
practicing in GEORGIA FACS IMILE 404/658"l725 professional law corporation
DALLAS SAN OlEGO
38M TURTLE CREEK BLVD. 1330 WELLS FARGO BANK BUILDING
SUITE IOSO lOl W. BROADWAY
DALLAS. TEXAS 75219 SAN DIEGO. CALIFORNIA 92IOI
2m/760-6766 6l9'23208<a8
MEMORANDUM
CONFIDENTIAL: ATTORNEY-CLIENT PRIVILEGED COMMUNICATION
TO: Richard G. Elkins
High Desert Investment Corporation
FROM: Hyatt & Rhoads, P.C.
DATE: December 5, 1991
RE: Meetings with Government Officials and Agencies
In preparation for upcoming meetings with the various
governmental bodies which will be involved in the High Desert
development process, Kurt Culbertson requested that we add our
suggestions to those which have already been given regarding
how to approach the various issues which may arise and how to
avoid common pitfalls in discussing future development plans.
The purpose of this memorandum is to identify some of the
issues which are normally of general concern to government
agencies (and builders, purchasers, and neighboring property
owners for that matter) and to offer some general guidance in
dealing with questions and making presentations.
As we may have mentioned previously, in our
experience, one of the most litigation-prone areas in the
development field concerns representations made or, more
commonly, the perception of what people think they have heard.
The fact is that such cases are fact-intensive, time-consuming,
and costly, even when the developer ultimately wins. The
worst-case scenario is one in which oral or written
representations become enforceable even when they are not the
real intention of the developer. Our comments in this memo are
designed to help you avoid those problems.
Common issues and concerns about which government
officials may seek assurances are listed below. We suggest
that you plan your answers on these and other subjects which